Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction for second-degree sexual abuse, holding that Defendant's constitutional right to a public trial was violated when the trial court closed his trial during the COVID-19 pandemic.Defendant was set to stand trial on felony charges in March 2020, but his trial was repeatedly rescheduled due to COVID. The district court ultimately concluded that allowing anyone in to attend Defendant's trial, including his family and friends, violated COVID protocols previously set by the Supreme Court. The district court also rejected the option of live-streaming the trial. The jury subsequently convicted Defendant of second-degree sexual abuse. The Supreme Court reversed, holding that the district court's exclusion of all members of the public from Defendant's trial violated Defendant's constitutional rights, requiring a new trial. View "State v. Brimmer" on Justia Law

In this interlocutory appeal, the Supreme Court reversed the decision of the district court ordering certain records produced to Plaintiff in discovery before trial, holding that the district court erred by relying on civil discovery rules to compel production of the records at issue.Plaintiff's daughter was killed in a motorcycle accident. Plaintiff brought a tort action against the driver of the motorcycle and settled without subpoenaing the county sheriff's investigative reports. After a criminal investigation and prosecution of the driver was complete Plaintiff brought this enforcement action under Iowa Code chapter 22 against the county sheriff's department seeking to obtain its complete investigation file. The district court ordered the records produced to Plaintiff in discovery before trial without ruling on their confidentiality. The Supreme Court reversed, holding that the district court erred in compelling disclosure of the sheriff's investigation materials to Plaintiff's counsel. View "Vaccaro v. Polk County" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting Defendant of first-degree burglary, first-degree robbery, assault causing serious injury while participating in a public offense and willful injury causing serious injury, holding that remand was required for entry of an order merging Defendant's conviction for willful injury causing serious injury with first-degree robbery.The court of appeals primarily affirmed the judgment of the district court but agreed with Defendant that his conviction for willful injury causing serious injury merged with his conviction for first-degree robbery. The Supreme Court affirmed, holding (1) the district court's rulings were all correct except as to Defendant's merger claim; and (2) a defendant's prior conviction for vehicular homicide by reckless driving under Iowa Code 707.6A(2) is a "crime of similar gravity" to a forcible felony for purposes of applying the sentencing enhancement set forth in Iowa Code 902.11. View "State v. Bloom" on Justia Law

The Supreme Court held that a spouse’s permanent disability suffered during the parties’ marriage may be considered when determining a traditional spousal support award, even if the length of the parties’ marriage does not quite meet the typical durational threshold.Jason and Erinn Mills married in 2006. Later that year, Erinn was injured while giving birth to the parties' only child, leading to her becoming permanently disabled. Jason filed for divorce in 2019. At issue on appeal was whether the fact that one spouse acquires a permanent disability during the marriage can support an award of spousal support when the length of the marriage would not otherwise support a traditional support award. The Supreme Court held (1) a court may appropriately consider a spouse's permanent disability acquired during the parties' marriage as a factor when determining a child support award; and (2) Erinn should be awarded traditional spousal support of $400 per month, but the amount should not increase upon the termination of Jason's child support obligation. View "In re the Marriage of Mills" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the decision of the district court affirming the Polk County assessor's original tax valuation of two large corporate office buildings in downtown Des Moines at $87,050,000 and $44,910,000, holding that the district court did not err by relying on the Board's expert appraisers when it affirmed the assessor's valuation.Nationwide Mutual Insurance Co., the owner of the buildings at issue, protested the valuation, and the Polk County Board of Review upheld the valuation. The district court affirmed the assessment after hearing appraisers appointed by both the Board and Nationwide as expert witnesses and finding the Board's experts more reliable. The court of appeals reversed and reduced the assessments. The Supreme Court vacated the appellate court's decision and affirmed the judgment of the district court holding (1) there was no basis to reject the district court's determination about the relative reliability of the expert witness testimony; and (2) the Board met its burden to prove that the valuation was not excessive. View "Nationwide Mutual Insurance Co. v. Polk County Board of Review" on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of the State, the Iowa Department of Corrections, and the director of the Iowa Department of Corrections (collectively, Defendants) and against Plaintiff on his claims of employment discrimination, holding that Plaintiff's constitutional claims failed.Plaintiff sued Defendants under the Iowa Civil Rights Act. On the morning of trial, Plaintiff objected to the composition of the jury venire, arguing that the jury venire did not represent a fair cross section of the community. The district court denied the challenge, ruling that the fair-cross-section requirement does not apply to civil jury trials. Thereafter, the jury found that Plaintiff failed to prove any of his claims. On appeal, Plaintiff argued that the Fifth and Seventh Amendments of the United States Constitution require that civil juries be drawn from a fair cross section of the community. The Supreme Court affirmed, holding that Plaintiff's federal claims failed. View "Savala v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for possession of a controlled substance with intent to deliver, holding that Iowa R. Evid. 5.106 and the common law doctrine of completeness cannot trump Iowa R. Evid. 5.402.Specifically, the Supreme Court held (1) Defendant's right to a jury drawn from a fair cross section of the community under Iowa Const. art. I, 10 was not violated; (2) Defendant's claims of ineffective assistance of counsel were not properly before the Court and must be raised in the first instance on postconviction review; (3) the district court did not abuse its discretion in excluding certain documents proffered by Defendant as a discovery sanction; (4) the district court did not abuse its discretion in showing the jury an abbreviated version of a law enforcement officer's bodycam video; and (5) the evidence was sufficient to support the convictions. View "State v. Tucker" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying relief in this declaratory judgment action to force a public referendum on the financing of a school district's proposed athletic stadium, holding that Plaintiffs failed to show prejudice to obtain judicial relief for a technical violation in their petition.Plaintiff-citizens collected signatures to force the public referendum at issue, but the school board determined that the number of signatures were insufficient to force a referendum. The school district, therefore, declined to accept the petition or proceed with the referendum. Plaintiff then brought this declaratory judgment action to force the referendum. The trial court granted summary judgment denying relief. The Supreme Court affirmed, holding (1) Plaintiffs' petition was facially invalid as lacking the requisite number of signatures; (2) the district court breached a directory duty under Iowa Code 277.7 to return the rejected petition, but Plaintiffs failed to show prejudice; and (3) therefore, Plaintiffs' due process claims failed, and summary judgment was proper. View "Save Our Stadiums v. Des Moines Independent Community School District" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree murder for killing his mother, holding that the district court did not err in admitting testimony from a probation officer and the mother's friend as statements of the mother's then-existing mental state under Iowa R. Evid. 5.803(3).Defendant's mother sent an email to Defendant's probation officer hours before Defendant killed her stating that she was "scared" and that she needed "help." During trial, Defendant's defense to the first-degree murder charge was that he acted impulsively out of rage. Over Defendant's objection, the trial court allowed the probation officer and the mother's friend to testify about the mother's fear of Defendant and her plan to stop financially supporting him. The Supreme Court affirmed, holding that the district court correctly admitted the two individuals to testify under Rule 5.803(3) about previous statements the mother made because they constituted relevant hearsay statements. View "State v. Thompson" on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals in this postconviction proceeding declining to reverse Appellant's second-degree murder conviction but ordering the return of a previously-forfeited $50,000 cash bond, holding that postconviction relief was not a proper way to overturn the forfeiture order.To obtain pretrial release, Defendant had to post a $200,000 cash bond with $50,000 subject to the condition that it would be forfeited for purposes of restitution if Defendant were convicted. Defendant was subsequently found guilty of second-degree murder. The district court denied Defendant's later-filed application for postconviction relief. The court of appeals reversed as to the bond forfeiture order, ruling that Defendant's counsel provided ineffective assistance in failing to challenge the order. The Supreme Court affirmed except as to the bond forfeiture issue, holding that postconviction relief was not available to set aside the order directing that Defendant's cash bond be forfeited for victim restitution. View "Farnsworth v. State" on Justia Law